Preferential tax treatment for limiting the financial cost of acquisition debt bt granting of tax reductions for the indebted holding for the takeover.
Combination of preferential regimes for preparing donations and/or successions with reduced tax cost: “pacte Dutreil”, tariff reduction, separation of ownership, establishment of a civil society, option for the split and/or deferred payment of rights.
Preferential tax regimes for reorganising companies with limited tax costs with, in return, phased reintegration and/or deferred unrealised capital gains while restructuring (capital gains tax deferral and tax reversals).
Preparation (data collection), declaration and submission of income tax (especially on property income and capital gains) and wealth tax for resident and non-resident taxpayers.
Establishment of foreign holding companies with minimal substance to prepare a cash transfer following profits in optimised tax conditions; dividend exemption, exemption from capital gains, deductibility of loan interest, no deduction of taxes at from holding company to the financial beneficiary
Board of investment services providers (PSI) on their VAT outlines as far as Undertaking for Collective Investment in Transferable Securities (UCITS) and management under mandate are concerned.
Combined implementation of tax and social security rules in order to reduce the overall tax ratio applicable to income from activities and property income for people who carry out most of or all of their business activates abroad.
Implementation of preparatory cross border property reorganisations to benefit limitations resulting from private international law relating to international recovery assistance.
Pre-litigation and litigation on the legality of parafiscal taxes in regards to the principles of French community law in order to challenge their legality, especially in the absence of notification to the commission in the event of a substantial modification of their regime and their quality of
Review of cost optimisation of territorial economic tax costs and risk assessment.
Employee share ownership and sui generis which develop indirect/additional compensation benefiting from a preferential tax and/or employment treatment in relation to a direct compensation as salary.
Techniques to offset the tax losses: restructuring regimes covered by French common law, transfer of assets, write-off of loans, subsidies, independent revaluation, etc.
Choosing the most appropriate tax vehicle: French listed property investment companies (SIIC), collective undertaking for real estate investment (OPCI), foreign structure, arbitration between transparent and opaque tax regimes etc.
Assessment and quantification of risks related to the regularisation of undeclared foreign assets by the heirs of the deceased. Comparison between adjustments associated with an unforeseen post-inheritance inspection and spontaneous regularisation by the heirs.
Property audit leading to the recommendation of the most appropriate tax revenues given the structure of revenues to mitigate income tax: LMP (non-professional furnished letting), Loi Girardin, French overseas departments and territories (DOM TOM), Share Savings Plan (PEA), high-risk mutual fund
Implementation of vehicles for transmission and management of assets in light of fiscal constraints of French domestic law for entities located in countries with privileged taxation. Management of reporting obligations.